Regulatory Alert (23-RA-02) Home Mortgage Disclosure Act Data Collection Requirements for Calendar Year 2023
Dear Boards of Directors and Chief Executive Officers:
If your credit union makes residential mortgage loans and meets all four criteria outlined below, you must comply with the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).
Regulation C requires you to collect HMDA data associated with mortgage loan applications processed during 2023 if:
- Your credit union’s total assets as of December 31, 2022, exceeded $54 million;
- Your credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2022;
- Your credit union originated at least one home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a first lien on a one-to-four-unit dwelling during 2022; and
- Your credit union originated at least 25 covered closed-end mortgage loans in each of the two preceding calendar years (2021 and 2022) or at least 200 covered open-end lines of credit in each of the two preceding calendar years (2021 and 2022).
If your credit union meets all four criteria, you must collect HMDA data during calendar year 2023 and submit the data to the CFPB no later than March 1, 2024.
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